Rajesh Goyal vs Laxmi Constructions
Supreme Court of India
CIVIL APPEAL NO. OF 2026
(@ Special Leave Petition (Civil) No.27184 of 2025)
Facts of the Case
The dispute relates to a tenanted bungalow (Municipality No. 2/1410/11, Old No. 43, Rose Bank, Ahmed Bagh/Chandranagar, Court Road, Saharanpur, Uttar Pradesh). The landlords (M/s Laxmi Constructions & Ors.) initiated eviction proceedings under Section 21(2) of the U.P. Urban Premises Rent Control Ordinance, 2021 (now Act) on the ground of non-payment of rent. The case was numbered as Case No. 2082/2022 before the Rent Authority (Additional District Magistrate (Administration), Saharanpur).
- On 07.09.2022, the Rent Authority held that a landlord-tenant relationship existed and directed the tenant to vacate within 30 days.
- This finding was upheld by the District Judge, Saharanpur in Rent Control Appeal No. 57/2022 on 22.01.2024.
- The Allahabad High Court confirmed the same in Matters under Article 227 No. 1821/2024 on 14.05.2024.
- The tenant’s Special Leave Petition (SLP(C) No. 21177/2024) was dismissed by the Supreme Court on 20.09.2024. While dismissing the SLP, the Court granted time to vacate till 31.03.2025 subject to filing an undertaking.
- Review Petition and Miscellaneous Application filed by the tenant were also dismissed on 18.03.2025 and 24.03.2025 respectively.
- Despite the finality of the eviction order, the tenant filed a restoration application (Case No. RST/2169/2025) before the same Rent Authority, which was surprisingly allowed on 15.05.2025.
- The landlords challenged this restoration order before the High Court in Writ Appeal No. 8420/2025. The High Court allowed the appeal on 17.07.2025, set aside the restoration order and remanded the matter for fresh decision under the relevant rules.
- Parallel contempt proceedings were initiated against the tenant for non-compliance with the Supreme Court’s 20.09.2024 order. On 09.09.2025, the tenant gave an undertaking to vacate within two weeks.
- The present Civil Appeal (arising from SLP(C) No. 27184/2025 filed on 19.09.2025) challenges the High Court’s order dated 17.07.2025.
The same Additional District Magistrate who passed the restoration order had, in her administrative capacity, submitted a report dated 31.12.2024 recommending action on the tenant’s complaint alleging that the landlords’ sale deed was forged.
Issues
- Whether the Rent Authority had jurisdiction to entertain and allow a restoration application after the eviction order had attained finality up to the Supreme Court.
- Whether the Rent Authority could go into the question of title/ownership or validity of the sale deed when the statute expressly limits its jurisdiction to the existence of landlord-tenant relationship only.
- Whether the Rent Authority’s order dated 15.05.2025 amounted to judicial indiscipline, overreaching, and abuse of process by ignoring binding orders of the Supreme Court and the High Court.
Analysis (Grounds from Appellant and Respondent)
Appellant’s Grounds (Tenant – Rajesh Goyal):
- The restoration application was maintainable on the basis of subsequent material (report of the ADM herself recommending criminal action against the landlords for allegedly forged sale deeds).
- The landlords had no valid title, therefore the entire eviction proceedings were vitiated.
- The Rent Authority was justified in recalling its earlier order in the interest of justice, especially when fresh facts regarding fraud in title documents had come to light.
Respondent’s Grounds (Landlords – M/s Laxmi Constructions & Ors.):
- The landlord-tenant relationship and the eviction order had attained finality after successive dismissals by three courts and the Supreme Court (including review and miscellaneous applications).
- Filing a restoration application after the Supreme Court had directed vacation by 31.03.2025 and the tenant had given an undertaking was a clear abuse of process and overreaching of this Court’s orders.
- Under Section 38 of the U.P. Urban Premises Rent Control Act, 2021, the Rent Authority has no jurisdiction to decide questions of title or ownership; its jurisdiction is limited to the tenancy agreement and landlord-tenant relationship.
- The same officer who, as ADM (Administration), had submitted a report on the alleged forgery could not, while acting as Rent Authority, use that report to nullify a judicial order passed after full adjudication up to the Supreme Court.
- The action of the Rent Authority was contrary to principles of judicial discipline, hierarchy of courts, and the doctrine that an order passed without jurisdiction is a nullity.
The Supreme Court observed that the tenant’s repeated attempts after finality of the matter, coupled with the Rent Authority entertaining the restoration application, constituted gross abuse of process. The Court further noted that the Rent Authority had mixed its administrative and quasi-judicial roles impermissibly.
Final Judgment
The Supreme Court declined to entertain the appeal on merits, holding it to be a gross abuse of the process of law and an attempt to overreach its earlier orders.
- The order dated 15.05.2025 passed by the Rent Authority allowing restoration was declared a nullity and void ab initio for want of jurisdiction.
- The tenant (appellant) was directed to deposit costs of ₹5,00,000 (Rupees Five Lakhs only) with the Supreme Court Middle Income Group Legal Aid Society.
- Show-cause notice was issued to the Additional District Magistrate (Administration), Saharanpur, for having passed the restoration order in complete disregard of binding orders of the Supreme Court and the High Court. However, on tendering an unconditional apology, the Court accepted the same and clarified that the proceedings shall not affect the officer’s career progression in any manner.
- The Court reiterated the binding principles of judicial discipline, hierarchy of courts, and the limited jurisdiction of Rent Authorities under the U.P. Urban Premises Rent Control Act, 2021. It emphasised that once an order attains finality up to the Supreme Court, no subordinate authority can sit in appeal or review over it.
- The Civil Appeal was disposed of accordingly. All pending applications stand closed.
Date of Judgment: 25 March 2026
Bench: Hon’ble Mr. Justice Sanjay Karol and Hon’ble Mr. Justice Nongmeikapam Kotiswar Singh
Citation: 2026 INSC 299
This judgment serves as a strong reminder on judicial discipline, the finality of orders, and the strict limits on the jurisdiction of Rent Authorities under the special statute.